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Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6653(a)(1)(A) 6653(a)(1)(B) 6661
1986 $590,852 $29,543 * $147,713
1987 254,088 12,704 * 63,522
1988 280,624 14,031** -- 70,156
* 50 percent of interest due on portion of
underpayment attributable to negligence.
** For 1988, the applicable addition to tax was
determined under sec. 6653(a)(1).
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
After concessions, the issues for decision are whether
Ambrosio G. Makalintal, petitioner’s former husband, and
petitioner underreported their income, and, if so, whether
petitioner qualifies as an innocent spouse under section 6013(e).
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
In 1967, Mr. Makalintal and petitioner were married in the
Philippines, and until 1985 (when they moved to the United
States), Mr. Makalintal and petitioner were residents and
citizens of the Philippines. Prior to their divorce in 1990,
Mr. Makalintal and petitioner had three children.
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